No. 25-1113

Jain-Miecell Roberson v. United States

Lower Court: Third Circuit
Docketed: 2026-03-24
Status: Pending
Type: Paid
Tags: None
Latest Conference: N/A
Question Presented (from Petition)

The Civil Service Reform Act of 1978 (CSRA), 5 U.S.C. § 1101 et seq., provides a comprehensive framework for reviewing adverse personnel actions against federal employees, channeling most claims to the Merit Systems Protection Board (MSPB) with judicial review exclusively in the Court of Appeals for the Federal Circuit. In Perry v. Merit Systems Protection Board, 582 U.S. 420 (2017), this Court held that "mixed cases"—those combining CSRA-covered personnel actions with discrimination claims under federal anti-discrimination laws—must be reviewed in district court under 5 U.S.C. § 7703(b)(2). However, this Court has not addressed whether claims alleging constitutional violations (e.g., due process deprivations) or state-law torts intertwined with CSRA-covered actions constitute "mixed cases" warranting district court jurisdiction, or whether such claims are preempted by the CSRA and funneled exclusively to the MSPB and Federal Circuit.

1. Whether a federal employee's claims alleging constitutional due process violations and state-law torts (e.g., negligence and emotional distress under Pennsylvania law) arising from a CSRA-covered personnel action (e.g., detail, transfer, or reassignment) constitute a "mixed case" eligible for district court review under Perry v. Merit Systems Protection Board, or whether such claims are precluded from district court jurisdiction by the CSRA's exclusive remedial scheme.

2. Whether the CSRA precludes district court jurisdiction over constitutional claims challenging the validity of a federal statute or regulation governing personnel actions, notwithstanding this Court's recognition in Elgin v. Department of the Treasury, 567 U.S. 1 (2012), that the CSRA does not bar all constitutional challenges, particularly where the MSPB lacks authority to adjudicate such claims.

Question Presented (AI Summary)

Question not identified.

Docket Entries

2026-03-03
Petition for a writ of certiorari filed. (Response due April 23, 2026)

Attorneys

Jain-Miecell Roberson
Jain-Miecell Roberson — Petitioner
United States
D. John SauerSolicitor General, Respondent